No subject

Thu Jul 26 08:50:44 UTC 2007

"The best reason for not approving OOXML/Ecma 376 as a global standard
is that it will encourage other vendors to push for multiple,
unnecessary standards rather than achieving consensus on a single
standard that will best serve the needs of all stakeholders, and not
individual proprietary vendors."

The Australian Commonwealth memorandum of understanding with Standards
Australia is certainly written around these kinds of values related to
public benefit and national interest. I understand that in negotiating
a useful and meaningful standard there will be competing and
challenging choices to make and that there has been a move toward
accepting plural standards for different vendors, possibly to reduce
contention in these processes. However I feel this move shifts the
contention into the marketplace and reduces the value of standards to
the wider community.

Existing standards which are contradicted by the material included in the OOXML
proposal include
- ODF (document xml)
- OOXML doesn't use the stablished SVG (vector based xml) but on the
contrary two private and exclusive formats, one of them legacy: VML and GraphML
- OOXML doesn't use the stablished MathML (mathematical markup) but
its proprietary format (already rejected by scientific editorials
which make deep use of that feature for Nature and Science)
- OOXML doesn't use the International date and time (ISO 8601), the
basic of all economic, legal and political transactions in world. On
the contrary uses two calendars, one limited to start recently, in
1904, and other the one used by the Roman Empire thousand of years
ago, the Julian Calendar.
Rather than passing a proposal which conflicts so fundamentally with
standards practice Microsoft should be encouraged to participate in
constructive collaboration on the development of those projects. This
would better serve the standards process than initiation of a second
set of materials which non-Microsoft people would have trouble
interoperating with, and which would undo our ability to share
information using conforming standards.

OOXML is not functionally open

The name of the proposal OOXML is Office Open XML, this is a
misleading name as the proposal is not fully open, its development has
not been open, process for new versions is suggested to be through
ECMA's closed process, the legal access to "enough rights to implement
the standard" are not clearly provided. Wording
inside the proposal includes 'wordwrap like Microsoft97' which is
subjective and unimplementable language and would be unlikely to pass
in a proper ISO process. The format includes proprietary binary
material which is not open.

This is perhaps a work which contributes to better documentation of
existing Microsoft formats in terms which are useful for Microsoft
related developers but it is not outward looking or well integrated
with ISO standards which it is likely to interface with.

Clients who believe they are moving from a closed format to an open
format will find it is only comparably more open but is not drafted in
a way to make it transparent or easy to avoid vendor lock in.

Making this a standard in my opinion makes the standards bodies
complicit in duping customers into adopting a format which is not
truly representative of the criteria which are normally recognised as

The value of formal standards

Standards are increasingly important as our economies and information
becomes more transnational. We cannot afford to be imprecise with data
working at the scales which
are now possible. Working with live transactional data would be a
situation where
explicit single outcome processes would be most important. Mapping
those sensitive projects to a format which is built on a single vendor
retrospective is not a recipe for safe eCommerce.

"[A] document, established by consensus and approved by a recognized
body, that provides, for common and repeated use, rules, guidelines or
characteristics for activities or their results, aimed at the
achievement of the optimum degree of order in a given context NOTE
Standards should be based on the consolidated results of science,
technology and experience, and aimed at the promotion of optimum
community benefits." -- ISO/IEC Guide 2:2004, Definition 3.2

The value of formal standards is to find a best practice approach to
common agreed functionality. To use that as a unifying reference point
in order to ensure
developers of systems have a way to map to an exact and accessible
reference. And that customers of products are able to choose from
solutions by a range of vendors and to move their information from one
to another without prejudice. This makes it possible for multiple
providers to participate in a market and for consumers to make
flexible choices about the formats and applications which suit their
needs on an ongoing basis.

I feel that Australian and other standards bodies need to take this
opportunity to review their function in society and to consider that
the point of difference they offer is to contribute a means for
finding negotiated best practice. This is a craft in the truest sense.
It involves people developing skills in understanding systems
objectively and in working through issues to find a useful and
reliable outcome.

Companies which have a large market share already enjoy a kind of
default standard status through cost to change, skill base or in some
cases through data lock-in. Formal standards processes need the
ability to attract quality participation in collaboration of standards
development by using processes which do not marginalise collaborative
processes and goals in favour of competitive processes. ie. Without a
focus on common interest and collaboration the formal process will
only be able to mirror market share and will not be able to move
Australia forward in a flexible and broadly useful manner.

ECMA fast track process

The ooxml proposal is a very large document(6000pages) and has been
pushed through in 6 months. It has been suggested in the Australian
meeting that this made it impossible to review. The volume/time
compares poorly with usual standards which are 50 pages and take
approximately 2 years to review thoroughly. ODF is 1000 pages itself
and is considered large for a standards document but at least it was
processed in an open way and there was room for all parties to
contribute to its definition as well as a standard process of review.

The ECMA fast track process is structured in such a way that it does
not honor aspirations of public benefit and national interest. The
value that ECMA offers its vendor customers is to "offer a path which
will minimise changes to input specs"

The process is a product offered to vendors by a provider who benefits
from being able to push through many projects. This means the original
relationship between the vendor and the ECMA organisation is based
around momentum and single source material with no benefit to either
party in providing real and rigorous review or participation in
development. This together with the idea that multiple vendors
offering vendor specific 'standards' is a workable approach are the
assumptions which derail the rest of the process.

While it is expected that there may be different approaches to
technologies and products, it is the role of a standards group to
identify points of best practice around which an industry can
integrate and offer flexible choices to consumers. This relies on
access to a process where the craft of standards writing is core,
where the considered and 'hands-on' input of many participants in the
given standard is facilitated and where the proposal is thoroughly
tested for its interoperability with existing standards.

Open review and participation in developing the standard is the means
by which unifying and consolidating outcomes are made. This is the
role which all groups interested in long term safe access to knowledge
look to standards bodies for.

Australian process and responsibility

I sense a 'good faith' spirit in the efforts of the Standards Australia staff.
However I feel that the fast track process applied to this proposal, both in
Australia and internationally, is structurally not able to deliver
outcomes in the Australian and public best interest. We need to
address these procedural issues prior to processing this proposal so
that it can be considered in a way which does address the goals of the
Commonwealth in applying these standards processes to proposals.
Difficulty in finding out information about the process has not
helped, including meeting information and formats for responses.

Australia as a country with an important role in these proceedings
should not take an uncritical role in these processes. There needs to
be a method for identifying when a new approach to processing
standards is disfunctional. It is in Australia's national interest to
understand the core function that open standards play in enabling all
businesses and organisations to safely participate in working to or
adapting from a standard format.

Accessibility and accuracy are prominent requirements within the
education sector.
As James Dalziel pointed out in the Australian meeting, Australia
leads on technologies for the education sector. Access to knowledge is
an increasing piority and being able to share information developed
with public funds is becoming an important issue. Organsiations which
are able to develop once and distribute the value across the sector
offer efficiencies which are valuable.

Australian companies and developers would find it expensive to
accommodate two complex and incompatible approaches to documents
requiring two approaches to each project they deliver. We need to be
more sophisticated in our choices because we need to be able to make
better value from smaller projects. Australia has many smaller players
which means we need to be able to do things in a develop once use
flexibly kind of way. Developers who produce technologies which help
with accessibility also need to be nimble and flexible to cater
effectively to small markets.

The University of Toronto recognises these issues "This paper
undertakes a preliminary analysis of the OOXML format with respect to
its accessibility, with emphasis on accessibility to persons with
disabilities. We will demonstrate that the OOXML format fails to
adequately support accessibility of documents."

Backwards compatibility

Work on translating the legacy document formats into an xml based
format is a worthwhile project. If Microsoft have a reliable tool for
mapping material out of those formats into parsable XML that is a
great step forward for their clients and for the ongoing relevance of
their applications. Unfortunately it is my understanding that the
technique for translating the documents involves embedding binary
material in the XML.

OOXML is also a new-'old format', the time, date, vector, math models
used in the new format are still reflective of historical choices and
do not represent current best practice. In order to truly be facing
forwards the material from the closed formats should be parsable XML
and to match existing ISO standards. If the OOXML approach is not able
to deliver on these outcomes then it is a great step forward from
opacity to translucency but is not the full journey.

Security, transactions and XML with embedded binary material

Transactions are not a point of difference to existing standards for OOXML.
Transactions are the normal function of XML and the specific focus of EBXML.
The OOXML approach to formats includes binary material.
Embedding binary material in transactional secure XML is likely to
cause security issues. The transactional material has been developed
only to work with MS
Internet Explorer which is the browser of choice for internet based
exploits. Designing a transaction solution around embedding unknown
content in an eCommerce context, to match only a singler vendor's
formats and applications would be unlikely to pass a regular standards


Australia's Standards organisation should vote no with comments.

The comments should reflect our concerns with the principles and
process of Fast Track standards development using ECMA.

The proposal should be put on hold until a review of the goals,
responsibilities and processes for formal standards are completed.

This to include establishing a standard independently known and safe
scoping for legal safety of any material which is ISO accredited. We
cannot rely on unseen information and vendor assurances. There should
be a known legal scope for all ISO standards.

The proposal could then be reconsidered, including whether a second
standard in this space is a useful project for good standards

These factors to be considered first before any further work and
consideration is given to working through the body of the proposal.

It is possible that after reconsidering the processes and overlap
between existing standards and OOXML that it might be possible to use
aspects of the translation from legacy formats to map to Open Document
Format and to translate from other non standard models to match other
ISO standards.

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